By accessing or using the Application, the Client Discovery Tool and/or using the Services, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may be updated from time to time to reflect changes to our practices (see Changes and Updates to this Policy).
a. “Personal Information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
b. “User” means you (in respect of accessing or using the Application, the Client Discovery Tool and/or the Services).
c. “User Data” means Personal Information, data, reports and other files, folders or documents in electronic form that a User of the Services stores within the Services.
2. Information We Collect About You.
We limit the personal information collected to only the information needed. We collect and use several types of information from and about you, including:
a. User-provided Information. When you use the Services as a User, you may provide and we may collect Personal information that we can reasonably use to directly or indirectly identify you, such as your name, name, date of birth, email, contact information, family information (including information relating to spouses, next of kin, their respective dates of birth, etc.), net worth, wills, powers of attorney and other key documents, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, credit card information, bio picture, social media username/handle and any other identifier we may use to contact you online or offline. Personal Information also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. Each User is responsible that they have a valid legal basis for processing the Personal Information of third persons through the Services. Each User is responsible for providing notice to third persons concerning the purposes for which their Personal Information is collected and how this Personal Information is processed in or through the Services as part of User Data. Where necessary under applicable law, each User is responsible for obtaining valid consents from third persons for processing their Personal Information through the Services before starting to process Personal Information.
b. Non-Personal Information. We collect information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of Users accessing a specific feature. We also collect non-personal details about your interactions with the Services, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Services (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
c. Technical information. We collect technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access the Services, and usage details.
3. How We Collect Information About You.
We may collect your information, through:
a. Direct interactions with you (and authorisations by you) when you provide it to us by using the Services or corresponding with us by phone, email, or otherwise.
b. Automated technologies or interactions, as you navigate through the Application.
c. The information we collect directly from you on or through the Services may include:
- Information that you provide by subscribing to or using the Services, filling in forms on the Application or requesting further services.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through the Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Services.
- Details of your visits to the Application, including traffic data and other communication data and the resources that you access and use on the Application.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
e. The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of the Application and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
4. How We Use the Information We Collect.
We use the information that we collect in a variety of ways in providing the Services and operating our business, including but not limited to:
a. Operations. We use information that we collect about you or that you provide to us, including any Personal Information, other than User Data, to:
- operate, maintain, enhance and provide all features of the Services;
- provide information that you request;
- provide you with notices about your account/subscription (including expiration and renewal notices);
- carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
- respond to comments and questions;
- provide support to Users; and
- for any other purpose with your consent.
b. User Data. We use User Data to:
- complete our questionnaires and provide recommendations and summaries for Users regarding tax, estate and financial planning;
- notify Users of key information and/or milestones;
- provide emails to Users; and
- otherwise in accordance with the directions provided by the applicable User.
c. Improvements. We use the information to:
- understand and analyze the usage trends and preferences of our Users;
- improve the Services; and
- develop new products, services, features, and functionality.
Should this purpose require us to process User Data, then the data will only be used in anonymized or aggregated form.
d. Communications. We may use a User’s email address or other information – other than User Data – to contact that User:
- for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the User Data or Personal Information posted on the Services; or
- with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under Your Choices.
e. Cookies and Tracking Technologies. We use automatically collected information and other information collected on the Services through cookies and similar technologies to:
- personalize the Services, such as remembering a User’s information so that the User will not have to re-enter it during an interaction or on subsequent interaction;
- provide customized advertisements, content, and information;
- monitor and analyze the effectiveness of Services;
- monitor aggregate site usage metrics such as total number of interactions; and
- track your entries, submissions, and status in any promotions or other activities on the Services.
You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
5. To Whom We Disclose Information.
Except as described in this Policy, we will not intentionally disclose User Personal Information or User Data that we collect or store on the Services to third parties without the consent of the applicable User or as otherwise required by law. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
a. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- Affiliates and Subsidiaries. We may disclose Personal Information that we collect or you provide as described in this Policy to our subsidiaries and affiliates.
- Services Providers. We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Information or User Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
- Non-Personally Identifiable Information. We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information, (“NPII”) available to third parties for various purposes, including: (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Services. Your Personal Information will not be shared with your employer or organization, except with your consent or as may be required by law. Your Personal Information will not be sold or provided to third parties for marketing or cold calls without your consent. For greater certainly, we will only share NPII for the purposes listed above.
- Law Enforcement, Legal Process and Compliance. We may disclose Personal Information or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
b. We also reserve the right to disclose Personal Information or other information that we believe, in good faith, is appropriate or necessary to:
- take precautions against liability;
- protect ourselves or others from fraudulent, abusive, or unlawful uses or activity;
- investigate and defend ourselves against any third-party claims or allegations;
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available; or
- protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
d. International Data Transfers. We may process, store, and transfer your Personal Information in and to a foreign country, including but not limited to, the United States, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation.
6. Your Choices.
a. Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from the Company. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
- Accessing and Correcting Your Personal Information. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.
We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your Personal Information, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation.
If you are concerned about our response or would like to correct the information provided, you may contact our Chief Privacy Officer at firstname.lastname@example.org.
d. Opting out from Commercial Electronic Messages. If you receive commercial electronic messages from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
It may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.
e. Third-Party Services. The Services may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
8. Data Security.
a. The security of your Personal Information is very important to us. We use organizational, technical, and physical measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure, including, but not limited to:
- Organizational. We limit access to Personal Information on a “need-to-know” and “need-to-use” basis, we use anonymized, aggregated data where Personal Information is not required and we do not use Personal Information for training purposes, including to test databases.
- Technical. We provide Users with passwords, limit permission to access the Services to authorized Users only and all Personal Information is encrypted at rest and traffic is encrypted using SSL technology.
b. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
c. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Application and/or the Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Application or in the Services.
9. Data Retention.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
10. Changes and Updates to this Policy.
It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat your Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Application. We include the date this Policy was last revised at the bottom of this Policy. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically reviewing this Policy to check for any changes.
11. How to Contact Us.
We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact us at:
Attn: Chief Privacy Officer
346 Logan Avenue
Toronto, Ontario, Canada
We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact our Chief Privacy Officer using the contact information listed above.
DATE: JUNE 26, 2023